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Gasiorowski concluded that, because of the stock's history
of low trading volume, it would be difficult to dispose of
petitioner's block of shares without incurring a significant
discount or devaluing the holding by dribbling it into the local
market over a period of time exceeding 8 years. We do not agree
with this conclusion.
Evidence of the quantity of shares that can be sold without
depressing their price is relevant to determining the magnitude
of the discount, if any, that should be applied to their value
for blockage. Therefore, we consider the number of shares that
were sold within a reasonable time of decedent's death, as well
as the price at which they sold, indicative of the fair market
value of the shares at the valuation date.
Gasiorowski based his estimate of the amount of time it
would take petitioner to dribble its stock into the local market
on the average number of shares sold per year during the 11 years
prior to decedent's death. We have found that the waiting list
of willing buyers maintained by Savings is evidence that the
stock's low trading volume is due to the shareholder's preference
for holding the shares for investment, not the lack of willing
buyers. By averaging the sales volumes of the prior years,
Gasiorowski diluted the evidence of the number of shares that
have been sold by willing sellers to willing buyers at any
particular time with the total number of shares that were offered
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